Timms v. Aspinwall

CourtDistrict Court, S.D. Georgia
DecidedSeptember 4, 2024
Docket2:23-cv-00105
StatusUnknown

This text of Timms v. Aspinwall (Timms v. Aspinwall) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Timms v. Aspinwall, (S.D. Ga. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA BRUNSWICK DIVISION

MICHAEL L. TIMMS,

Plaintiff, CIVIL ACTION NO.: 2:23-cv-105

v.

FRANK ASPINWALL, STEPHEN TILLMAN, and THE STATE OF GEORGIA,

Defendants.

O RDE R Plaintiff filed this action, asserting claims under 42 U.S.C. § 1983. Doc. 1. This matter is before the Court for a frivolity screening under 28 U.S.C. § 1915A. For the reasons stated below, I DISMISS Plaintiff’s Complaint in its entirety, DIRECT the Clerk of Court to CLOSE this case and enter the appropriate judgment of dismissal, and DENY Plaintiff leave to proceed in forma pauperis on appeal.1 PLAINTIFF’S CLAIMS2 Plaintiff is a prisoner at Hays State Prison in Trion, Georgia, and initially submitted his Complaint with the District Court for the Northern District of Georgia. Doc. 1 at 2. That court transferred Plaintiff’s cause of action to this District because Plaintiff complains of events occurring in Glynn County, Georgia. Doc. 3. Plaintiff alleges on August 5, 2011, he was

1 Plaintiff has consented to the undersigned’s plenary review. Docs. 6, 9.

2 All allegations set forth here are taken from Plaintiff’s Complaint. Doc. 1. During frivolity review under 28 U.S.C. § 1915A, “[t]he complaint’s factual allegations must be accepted as true.” Waldman v. Conway, 871 F.3d 1283, 1289 (11th Cir. 2017). coerced to agree to a plea deal of 20 years’ imprisonment for committing a robbery. Doc. 1 at 4. Plaintiff alleges he attempted to withdraw his plea on August 11, 2011, and Defendant Tillman forced him to not withdraw. Id. Plaintiff alleges this prevented him from receiving a bench trial, which would have allowed him to receive judgment to seek treatment for his ongoing mental

health conditions. Id. Plaintiff alleges he was not given a psychological evaluation, which would have shown he was incapable of understanding the nature of his plea deal. Id. at 5. Plaintiff alleges this is a violation of his due process rights and he has been falsely imprisoned and maliciously prosecuted. Id. at 4–5. Plaintiff seeks release from his sentence and monetary damages. Id. at 5. STANDARD OF REVIEW A federal court is required to conduct an initial screening of all complaints filed by prisoners and plaintiffs proceeding in forma pauperis. 28 U.S.C. §§ 1915A(a), 1915(a). During the initial screening, the court must identify any cognizable claims in the complaint. 28 U.S.C. § 1915A(b). Additionally, the court must dismiss the complaint (or any portion of the

complaint) that is frivolous, malicious, fails to state a claim upon which relief may be granted, or which seeks monetary relief from a defendant who is immune from such relief. Id. The pleadings of unrepresented parties are held to a less stringent standard than those drafted by attorneys and, therefore, must be liberally construed. Haines v. Kerner, 404 U.S. 519, 520 (1972). However, Plaintiff’s unrepresented status will not excuse mistakes regarding procedural rules. McNeil v. United States, 508 U.S. 106, 113 (1993). A claim is frivolous under § 1915(e)(2)(B)(i) if it is “without arguable merit either in law or fact.” Moore v. Bargstedt, 203 F. App’x 321, 323 (11th Cir. 2006). In order to state a claim upon which relief may be granted, a complaint must contain “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). To state a claim, a complaint must contain “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not” suffice. Twombly, 550 U.S. at 555.

DISCUSSION I. Plaintiff’s Claims for Injunctive Relief Plaintiff argues he has been falsely imprisoned and his confinement is unconstitutional. This is construed as a request for injunctive relief in the form of release from state custody. However, a “prisoner in state custody cannot use a § 1983 action to challenge ‘the fact or duration of his confinement.’” Wilkinson v. Dotson, 544 U.S. 74, 78 (2005) (quoting Preiser v. Rodriguez, 411 U.S. 475, 489 (1973)); see also Johnson v. Chisholm, No. 4:09-cv-143, 2009 WL 3481904, at *1 (S.D. Ga. Oct. 28, 2009) (explaining a pretrial detainee seeking preliminary and permanent injunctions of his state criminal proceedings, dismissal of his state charges, and immediate release failed to advance a cognizable claim under § 1983 because his sole remedy

was to file a habeas petition under 28 U.S.C. § 2241). To the extent Plaintiff is challenging the fact and duration of his confinement and is seeking release from that confinement, he is requesting habeas corpus relief. As for the proper form of habeas relief, “for those imprisoned pursuant to a State court judgment, we held that the habeas corpus remedy is authorized by § 2241, but also subject to § 2254 and all of its attendant restrictions.” Peoples v. Chatman, 393 F.3d 1352, 1353 (11th Cir. 2004). Accordingly, to the extent Plaintiff seeks injunctive relief to release him from state custody, this portion of Plaintiff’s filing is construed as a § 2241 habeas corpus petition rather than a § 1983 complaint. Before bringing a federal habeas action, a plaintiff is required to fully exhaust state remedies. Wilkinson, 544 U.S. at 79 (citing Preiser, 411 U.S. at 486). Here, there is no indication Plaintiff has fully exhausted his state remedies, and he has not satisfied a necessary prerequisite for filing a federal habeas petition. Therefore, I DISMISS Plaintiff’s claim for injunctive relief.

II. Plaintiff’s Legal Assistance Claims Plaintiff fails to state a § 1983 claim against his public defender, Defendant Stephen Tillman. To state a claim for relief under § 1983, a plaintiff must allege he was deprived of a federal right by a person acting under color of state law. Hale v. Tallapoosa County, 50 F.3d 1579, 1581 (11th Cir. 1995). “[A] public defender does not act under color of state law when performing a lawyer’s traditional functions as counsel to a defendant in a criminal proceeding.” Polk County v. Dodson, 454 U.S. 312, 325 (1981). Plaintiff’s claim against Defendant Tillman is based upon allegations he provided Plaintiff with ineffective legal assistance in his state criminal proceedings. Thus, even if the allegations in his Complaint are true, Plaintiff’s public defender was not acting under color of state law and may not be sued under § 1983.

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Bluebook (online)
Timms v. Aspinwall, Counsel Stack Legal Research, https://law.counselstack.com/opinion/timms-v-aspinwall-gasd-2024.